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US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules. The first article of this series provided the general reporting requirements under Form 5471 which was followed by the second article of this series about the reporting requirements of “Category 2 Filers”, which are the reporting requirements of a US citizen or resident who is an officer or director of a foreign corporation. This article will focus on the reporting requirements of “Category 3 Filers”, which are the reporting requirements that are generally triggered when US persons acquire and dispose of stock in a foreign corporation.

An individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien even though the individual may live in the US for an extended period of time. Generally, nonresident aliens are not subject to US capital gains tax with the exception of real property located in the US. However, there is an exception to this rule for nonresident aliens who have been in the US for more than 182 days in a given year.

December was a fruitful month for the US Treasury Department’s efforts to implement FATCA. The Treasury Department inked another six FATCA bilateral agreements which increases the total number of bilateral agreements to 18. The Malta, Netherlands, Guernsey, Isle of Man, Jersey agreements are based on the Model 1A treaty and requires the foreign financial institutions…

US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules. The first article of this series provided the general reporting requirements under Form 5471. This article will focus on the reporting requirements of “Category 2 Filers”, which are the reporting requirements of…

An individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien, even though the individual may live in the US for a number of years and even have his/her principal residence here. Generally, when individuals who meet certain requirements sell their principal residences, they receive an exclusion…

Thanksgiving was quite a feast for the US Treasury Department. On November 26, 2013, the US and Costa Rica signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA) and on November 28, 2013, the US and the Cayman Islands signed a bilateral agreement to implement FATCA. The Costa Rican agreement is…

As we approach the end of 2013, with the House scheduled to be in session for less than three more weeks this year, it appears highly unlikely that we will see any comprehensive U.S. tax reform in 2013. This provides numerous opportunities for taxpayers, because many techniques for tax minimization are likely to remain available,…

US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES Here we will briefly discuss the ownership attribution rules for purposes of Form 5471, and introduce the different filing categories under Form 5471. The rules and reporting requirements for each category of filer are unique and will be discussed in more detail in subsequent articles. Before describing the…

US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you have no US source income. Well, that’s not all. This is the first in a series…

US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you have no US source income. Well, that’s not all. This is the first in a series…